SecProbe.io

July 1, 201 3

Via E -mail
Karl W. Mueller
Senior Vice President, Chief Financial Officer, and
Principal Accounting Officer
Old Republic International Corporation
307 North Michigan Avenue
Chicago, I L 60601

 Re: Old Republic International Corporation
 Form 10 -K for the Fiscal Year Ended December 31 , 2012
Filed March 1 , 2013
File No. 001-10607

Dear Mr. Mueller :

We have limited our review of your filing to your financial statements and related
disclosures and do not intend to expand our review to other portions of your document.    In our
comment s, we ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within 10 business d ays by providing the requested
information or by advising us when you will provide the requested response.  If you  do not
believe a commen t applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR u nder the form type label CORRESP that keys your
response s to our comment s.

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Management Analysis of Financial Position and Results of Operations
Executive Summary, page 32

1. You use the non -Gaap measure, Net Operating Income (Loss ), which was a loss of $99.7
million in 2012.  Please provide us proposed disclosure to be included in future filings  that
reconciles this non -Gaap measure to t he most directly comparable Gaap measure as required
by Regulation S -K 10(e).  The tabular disclosure on page 34 showing the composition of
realized gains or losses does not appear to meet this requirement.

Karl W. Mueller
Old Republic International Corporation
July 1, 2013
Page 2

 Notes to Consolidated Financial Statements
Note 1 – Summary of Significant Accounting Policies
(s) Regulatory Matters, page 87

2. Please provide us proposed disclosure to be included  in future filings that states  the amount
of statutory capital and surplus necessary to satisfy regulatory requirements, if significant in
relation to the entity’s statutory capital and surplus, or state that such amount is not
significant.  Refer to ASC 944 -505-1b.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filin g include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsibl e for the accuracy
and adequacy of the disclosures they have made.

In responding to our comment s, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the f iling;
 staff comment s or changes to disclosure in response to staff comment s do not foreclose
the Commission from taking any action with respect to the filing; and
 the company may not assert staff comment as a defense in any proceeding initia ted by the
Com mission or any person under the federal securities laws of the United States.

You may contact Tabatha Akins, Staff Accountant, at (202) 551 -3658 or Joel Parker ,
Account ing Branch Chief , at (202) 551 -3651 if you have any questions regarding the
comments.   In this regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

  /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant